ICD-10-CM/PCS: The Good News, the Bad News, and Potentially No News

November 7, 2008

Our current diagnosis coding system, ICD-9-CM, is out of date. Accommodation for new classifications results in limited and scattered entries. Is it time for the United States to start using ICD-10?

ICD-10 was released by the World Health Organization in 1994. ICD-10 is used by 138 countries (including the United States) for mortality reporting and by 99 countries for morbidity reporting. At least 11 countries use ICD-10 to determine case mix or reimbursement in some way. In the US, ICD-10 has been further modified to ICD-10-CM (Clinical Modification) with the support of many specialty societies.

Recently, the Centers for Medicare & Medicaid Services (CMS) proposed two rules in the Federal Register regarding implementation of

HIPAA 5010 Transaction Standards

ICD-10-CM (diagnosis codes) and ICD-10-PCS (procedure codes used only by hospitals) one year later

Implementation of the transaction standards is necessary to allow use of the ICD-10-CM/PCS codes.

CMS plans a teleconference for physicians about ICD-10-CM on November 17, 2008. The details for this teleconference are pending and will be provided on AAN.com when available.

The Good News

For clinical purposes, ICD-10-CM is a much better system of classification. Although there are significantly more codes in ICD-10-CM, many only reflect laterality, especially in regard to injuries. The chapter containing most neurology codes is not expanded as extensively as some other chapters, but the classifications are significantly more advanced than ICD-9-CM. The chapter is ordered much like ICD-9-CM, so that navigation will not be foreign to those familiar with the older classification system. The rules for using the codes will be much like those for ICD-9-CM. A crosswalk of ICD-9-CM codes to ICD-10-CM codes is already available on the CMS website.

ICD-10-CM has been tested in the field by the American Health Information Management Association and the American Hospital Association. This testing included some physician practices. These experienced coders found the system easy to use with only a few hours of instruction, but recommended that physicians themselves should have instruction to become familiar with the system ahead of implementation.

The Bad News

Although there is a crosswalk available that would allow use of "legacy" billing systems, it is not clear how long this will be possible after implementation. Many practices have agreements with their computer billing system providers for updates that should cover both the 5010 Transaction Standards and ICD-10-CM changes. Others with older systems may need to invest in major changes. Electronic health record (EHR) systems that have coding packages will need updates as well. There will be some costs for education of the office coders and physicians.

Though CMS aims for smooth transition in system change, we have learned from experience to expect delays and complications. Hopefully, the crosswalk will prevent any delay in payments if vendors are not ready for the transition. The American Academy of Neurology Professional Association is advocating for more time between implementations to allow full use of the transaction standards before switching to ICD-10-CM.

Potentially No News

The deadline for response to the proposed rules was October 21, 2008. On November 4, US voters chose a new administration, and it is likely that we will have a new Secretary of Health and Human Services in 2009. It is therefore somewhat unlikely that there will be a final rule in the near future. That said, the absence of an implementation date is not good news. We need a date to plan and train for ICD-10-CM.

What Neurologists Should Do

ICD-10-CM is coming eventually as a part of the HIPAA legislation. When there is a firm implementation date, the Academy will develop instruction opportunities for its members and a checklist of recommended steps to make the transition easier. In the meantime, ICD-10-CM is available for download, and interested members may want to explore the diagnoses they use most often. (Most neurology codes begin with the letter "G." Cerebrovascular disease codes begin with the letter "I." Symptom codes begin with the letter "R.") When negotiating contracts with EHR and office billing systems, be sure that they will accommodate both the 5010 Transaction Standard changes and ICD-10-CM in the future.

Within the past 24 months, Dr. Powers served as an expert witness in a case involving documentation, and in another case regarding traumatic brain injury. She also acted as a consultant in one additional case.